CLA-2-47:S:N8:234 805466

Mr. Daniel T. Petrosini
Alpha International
40 Parker Road, Suite 201
Elizabeth, N.J. 07207

RE: The tariff classification of ground wood pulp (powdered cellulose) from Germany.

Dear Mr. Petrosini:

In your letter dated December 21, 1994, on behalf of Markan Global Enterprises (Hackettstown, N.J.), you requested a tariff classification ruling. The product in question, known as "Elcema P 100," is described as a highly pure pharmaceutical auxiliary material derived from wood, without the use of any additives or other components.

A sample was submitted and has been analyzed by the New York Customs Laboratory. The lab finds the material to be a white powder composed of ground-up chemical bleached sulfate pulp fibers. The fibers are less than 0.05 mm in width, and range from less than 0.05 mm to 0.45 mm in length.

The applicable subheading for the "Elcema P 100" will be 4702.00.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for chemical woodpulp, dissolving grades...sulfate or soda. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director
New York Seaport